Skip to content

Tax Court finds a predictive coding response to the IRS complete

In July 2016 the US Tax Court held that a predictive coding response to the IRS was complete. The model sorted about 406,000 documents into a production set of about 180,000, at 3% precision.

  • 1 an organization

    The taxpayers met the request with a set that the model chose from about 406,000 documents, and the order states no time or cost saved.

Depth runs from 1, a convenience or time saved, to 5, a life or a livelihood preserved.

Status
Reported and intended benefits.
Evidence

found, the grade of this recordstudiedreportedclaimed

An independent court document supports the benefit.

The system’s part
Not isolated. The court judged whether the response met the discovery rules and did not compare the model with a full human review. It assumed for argument that the model's recall fell short and noted a precision of 3%. The model learned from seed sets that the Commissioner coded.
Limits
Not yet checked.
Costs and harms
Not yet checked.
Later
Not yet checked.
Benefit type
Repetitive Task Automation
System
Predictive coding algorithm
Made by
Not named in the order
Used by
Dynamo Holdings Limited Partnership and Beekman Vista, Inc. (petitioners)
Where
United States
Stage
In a pilot
Date
, when the source was published
Kind
Benefit created
Broad benefit
Processing Information, Getting Information
Collections
Scrutiny and findings
Last revised
31 October 2026

Sources

  1. Court document, by authors with no tie to the system.

    United States Tax Court (Judge Ronald L. Buch). Dynamo Holdings Limited Partnership v. Commissioner, Docket Nos. 2685-11 and 8393-12, order of 13 July 2016 denying the Commissioner's motion to compel. Copy of the signed order on the eDiscovery Law blog of K&L Gates.

    Petitioners made a reasonable inquiry in responding to the Commissioner's discovery demands when they used predictive coding to produce any documents that the algorithm determined was responsive, and petitioners' response was complete when they produced those documents.

Details

AI system

Workflow

The Commissioner coded the seed sets that trained the model and chose its recall rate. The parties agreed on a protocol and filed 16 joint status reports. A second algorithm screened the production set for privileged material.

Follow-up

Conditions for replication

The requesting party takes part in training the model. The court measures the response by a reasonable inquiry and does not demand perfection.

Entry details

Sector

Legal services / e-discovery.

Purpose

A vendor that the order does not name built the predictive coding software to find responsive documents, with a model trained on the requesting party's coding.

Not yet checked: model, release, provider, role, configuration, inputs and outputs, autonomy, human oversight, AI contribution, beneficiaries, reach, distribution and access, duration, every measurement question, every money question, ownership and control, dependencies, cross-border connections, geopolitical implications, replication attempts, availability, institutional decision, grounds, action and result, success criterion, every evidence question, observed or intended, alternative assessments, related entries, other identifiers, category mappings.

Cite this record

Peter H. Vartanian. (2026). Tax Court finds a predictive coding response to the IRS complete (AIBD-0834). Artificial Intelligence Benefits Database, edition of 31 October 2026. https://petervartanian.xyz/aibd/records/AIBD-0834.html (archived at https://doi.org/10.7910/DVN/AADSII, version 4.0)

BibTeX Data Field definitions